Springs Valley Bank and Trust
From: Darren Patterson [mailto:dpatterson@svbt.com]
Sent: Thursday, September 23, 2004 3:35 PM
To: Comments
Cc: psmith@aba.com; Debbe Beatty
Subject: RIN No. 3064-AC50
FDIC’s
Proposal to Increase the CRA Small Bank Threshold to $1 Billion
1500 Main Street
Jasper, IN 47546
September 23, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW Washington, DC 20429
Re: RIN Number 3064-AC50: FDIC Proposed Increase in the Threshold
for the Small Bank CRA Streamlined Examination
Dear Sir:
My name is Darren
Patterson of Springs Valley Bank and Trust, located in Jasper,
Indiana, which
is a small town of 12,000 residents. My
bank is $222 Million is assets. I am writing to strongly support
the FDIC’s proposal to raise the threshold for the streamlined
small bank CRA examination to $1 billion without regard to the size
of the bank’s holding company. This would greatly relieve the
regulatory burden imposed on many small banks such as my own under
the current regulation, which are required to meet the standards
imposed on the nation’s largest $1 trillion banks.
I understand that this is not an exemption from CRA and that my
bank would still have to help meet the credit needs of its entire
community and be evaluated by my regulator. However, I believe that
this would lower my current regulatory burden significantly. I also
support the addition of a community development criterion to the
small bank examination for larger community banks.
In conclusion, I believe that the FDIC has proposed a major improvement
in the CRA regulations, one that much more closely aligns the regulations
with the Community Reinvestment Act itself, and I urge the FDIC to
adopt its proposal.
Sincerely,
Darren C. Patterson
Credit Analyst
Springs Valley Bank and Trust
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